CRITICAL ANALYSIS ON EUTHANASIA VIS-À-VIS RIGHT TO DIE WITH DIGNITY
Author: Muskan Sharma
Co-Author: Pushkar Bhandarkar
Amity Law School, Amity University Chhattisgarh
Euthanasia means a deliberate action taken to end one’s life to relieve persistent pain and suffering. With scientific and technological development, ideas related to life and death have changed drastically. Modern techniques like ventilation and artificial nutrition can prolong a person’s life. Right to Life is an important right enshrined under Article 21 of the Constitution of India. It provides that an individual has a right to live his life with dignity till he dies, now a debatable issue arises whether this Right includes Right to a Dignified death? After several debates, the Judiciary in Aruna Shaunbag’s case and Common Cause case opened the door for legalizing Passive Euthanasia.
The absolute denial of autonomy over one’s body is a clear violation of natural rights. A person should have the last word in the matter of his life. Right to Life is more than just animal existence, it should be accompanied with quality and if such quality does not exist then a person should have the Right to Die. This issue of Euthanasia is widely debated all around the world as the emanating concerns of human rights.
This paper deals with the meaning, concept, and classification of Euthanasia. This paper also talks about whether the Right to life includes the Right to Die or not. It also describes Euthanasia in terms of Law commission’s recommendations and concludes by discussing the laws on Euthanasia in other countries.
Keywords:- Euthanasia, Right to Die, Constitution, Aruna Shanbaug’s case, Section 309 IPC…
“Life sans dignity is an unacceptable defeat and life that meets death with dignity is a value to be aspired for and a moment for celebration.”
– Dipak Misra (Former C.J.I.)
Life is a precious gift of God. Every Human Being desires to live his life to its fullest, but sometimes a person is made to face certain challenges that he wishes to end his life. Ending one’s life in a non-natural way is a sign of abnormality. When a person ends his life by his own acts, it is regarded as ‘Suicide’ but ending the life of a person by others on his request is regarded as ‘Mercy Killing’ or ‘Euthanasia’. Euthanasia is putting an end to the life of a very sick person in order to relieve him from immeasurable pain and suffering for the rest of his life. A severely ill or handicapped person must have the right to choose to live his life or die. The term Euthanasia was derived from the Greek word ‘Eu’ and ‘Thanatos’ meaning easy or good death. It literary means putting a person to easy and painless death especially when the person is suffering from incurable illness or when his life becomes meaningless as a result of physical or mental handicaps.
The day a person is born he is provided with basic human rights. Right to Life is the most essential right bestowed to a person by the virtue of him taking birth as a human being. Now a question arises that if a person has the right to live, whether he has a right not to live i.e. right to die. Euthanasia is a controversial and debatable subject all over the world as it involves the values, believes, and morals of our society. The debate has become very significant because of many recent developments in England and the Netherlands where Euthanasia has been allowed. The Hon’ble Supreme Court of India in Aruna Ramchandra Shanbaug’s case gave its decision allowing ‘Passive Euthanasia’ in India.
Meaning and Types of Euthanasia
The Black’s Law Dictionary defines euthanasia as the act or practice of killing or bringing the death of a person suffering from an incurable disease or is in any critical condition, for reasons of mercy.
According to Webster– The act or practice of killing or permitting the death of hopelessly sick or injured individuals in a relatively painless way for reasons of mercy. It is a process where the life of a human being is ended mostly to avoid the painful effects of any disease or illness.
In simple words, Euthanasia is the practice of ending the life of a person mercifully to release him from an incurable and intolerable pain, misery, and suffering for the rest of his life.
The main intention behind Euthanasia is to ensure a less distressing and painful death to a person who is suffering from an incurable disease for a very long time.
Euthanasia can be classified as follows
- Active Euthanasia– In Active Euthanasia a person’s life is put to an end for merciful reasons using lethal substances or forces so that the person dies painlessly. Active Euthanasia means any treatment by a physician with the intention of causing the death of another human being who is severely ill with the motive to relieve him from great suffering and pain. In Active Euthanasia an act is required to deliberately cause a person’s death.
The two features of Active Euthanasia are:-
- It involves an overt act in order to cause the death of a person.
- Lethal agents or forces are used.
For example- A lethal dose of a drug given to a person to end a painful period of dying
In the case of Airedale N.H.S. Trust v. Bland, Lord Keith stated: “life’s sanctity is not absolute, it prohibits the taking of active measures to cut short life of a terminally ill patient”.
- Passive Euthanasia– It means withdrawing the artificial life support system or necessary medical treatment for continuance of a person’s life. Passive Euthanasia is when the death of the person is brought by an omission. It means not using any extraordinary life-saving measures to keep a person alive. Here the death of a person is caused by omission and not by any overt act. In Passive Euthanasia the persons are not actively killed but they are simply not saved from dying.
- Switching off a life support system so that the person dies.
- Not carrying surgery that will extend the life of a person for a short period of time.
The Hon’ble Supreme Court in the case of Aruna Ramchandra Shanbaug v. Union of India, legalized Passive Euthanasia.
The difference between Active Euthanasia and Passive Euthanasia lies in their moral acceptance. Passive Euthanasia is permissible sometimes whereas Active Euthanasia is always prohibited because Doctors do not actively kill the patients, they simply do not save them. This distinction is the same as the distinction between killing and letting die.
- Voluntary Euthanasia– It is when the patient gives his consent to Euthanasia. In this type of Euthanasia direct action is done by a person in response to the patient’s request. The request in this case must be made by the person who is suffering from a terminal illness. The cognitive ability and rational consent of the patient for Euthanasia are known as Voluntary Euthanasia. It is primarily concerned with the right of the patients to choose to live his life or die.
For Example– Refusal to eat medicines or requesting to stop the life support system.
- Involuntary Euthanasia– It is conducted without the consent and the will of the patient. This is an act that involves ending the life of a patient without his personal request. Involuntary Euthanasia a patient’s life is taken without the expressed wish. This type of Euthanasia clearly amounts to an offence.
- Non-Voluntary Euthanasia– It is when the patient is in unconscionable condition or other reasons like insanity, young age, infancy due to which he is unable to make appropriate decisions between life and death, and the decision is taken by an authorized person on his behalf. In this type of Euthanasia, the consent of the patient is not available due to lack of capacity to give consent so the consent is given by the parent, spouses, children, or close relatives of the patient.
For Example– Parents can take meaningful decisions on behalf of their young baby in case of an incurable illness.
DOES ARTICLE 21 INCLUDES RIGHT TO DIE?
Life has always been considered as valuable, sacred, inviolable, and is worthy of protection and respect. Life comes in existence from the beginning and is protected until death arises. Life is placed on the highest platform by human beings as it is a gift of God. Obliteration of life is not only to an ethical or moral wrong but it is also punishable as a legal wrong. The Right to life of individuals is protected by all the democratic States. Likewise, the Indian Constitution under Article 21 provides that “no person shall be deprived of his life or liberty except according to the procedure established by law.”
In the case of Maneka Gandhi v. Union of India, the Apex Court of India held that life under Article 21 does not mean mere animal existence but it means a dignified life.
Now a question arises whether the Right to dignified life includes the Right to die? The question was answered by Hon’ble Judiciary.
In the State of Maharashtra v. Maruti Sripati Dubal, it was held that the right to life under Article 21 includes the right to die. The Bombay High Court, in this case, held, Section 309, Indian Penal Code, 1860 unconstitutional and violative of Article 14 and Article 21. The Court held that the desire to die is not unnatural rather just uncommon and abnormal. The court also listed the various circumstances under which people may end their lives including diseases, unbearable conditions of life, etc. But Euthanasia and suicide cannot be at the same footing. Hence, it was held that Euthanasia is homicide, be it under any circumstances, and is an offence under the IPC unless the law makes some exceptions.
In Chenna Jagadeeswar v. State of Andhra Pradesh, it was held by the Court that the right to die is not covered under the ambit of Article 21 and Section 309 of the IPC, 1860 is constitutional.
The Supreme Court in the case of P. Rathinam v. Union of India, held Section 309, of the IPC, 1860 as unconstitutional as being violative of Article 14, but upheld its validity based on Article 21 of the India Constitution contending that Article 21 includes the “right not to live a forced life”.
In the case of Gian Kaur v. State of Punjab, a five Judge bench of the Supreme Court overruled P. Rathinam’s case and held Section 309 as constitutional and said:
“When a man commits suicide, he has to undertake certain positive overt act and the genesis of those acts cannot be traced to, or be included within the protection of the right to life under Article 21. The significant aspect of the sanctity of life is not to be overlooked.”
The court declared that “right to life” includes the right to live with dignity up to death and includes a dignified procedure of death but dying with dignity is not the same as dying unnaturally during a person’s lifetime.
ARUNA SHANBAUG’S CASE: THE TURNING POINT IN THE INDIAN PERSPECTIVE OF EUTHANASIA
The Hon’ble Supreme Court of India legalized passive euthanasia under strict guidelines. The Court legalized passive euthanasia by permitting the withdrawal of life support systems to patients in a permanent vegetative state. This decision was a part of the verdict in a case involving Aruna Shanbaug, who was in a Persistent Vegetative State (PVS) until she died in 2015. The historic judgment was passed in the wake of Pinki Virani’s plea filed in December 2009 as a “Next Friend”. It is a landmark law that gives the power of choice in the hands of an individual, over & above religious, medical, or government control.
Facts & Judgement
Aruna Shanbaug was employed as a nurse in the King Edward Memorial Hospital, Mumbai. On 27 November 1973, she was attacked by Sohanlal Walmiki (a sweeper), while being attacked she was strangled with a dog chain because of which the oxygen supply to her brain stopped and she was left in a vegetative state. She was surviving on mashed food and was not able to move at all, also there was no scope of any improvement in her condition and she was dependent upon KEM hospital. On Aruna’s behalf her friend Pinki Virani, a who was social activist filed a petition before the Supreme Court arguing that the “continued existence of Aruna violates her right to live with dignity”. After 36 years of pain suffered by Aruna, Hon’ble Supreme Court delivered its Judgement on 7 March 2011. The court was of the opinion that Aruna’s case was not fit for Euthanasia as her brain was not dead. She could breathe without any life support system and her condition was stable. Removing the life support system, in this case, would mean not feeding her which cannot be equated with the removal of a ventilator. Also, the hospital staff did not support Euthanasia for Aruna. But the Court issued a set of broad guidelines legalizing passive euthanasia in India.
The guidelines are as follows:
- The decision to remove life support system must be taken by the parents, spouse, close relative, or in their absence by the next friend of the patient.
- The attending doctor’s advice must be given due weightage in taking the decision.
- An application under Article 226 before the High Court has to be filed.
- The bench will consist of the Chief Justice of High Court and at least two other judges.
- A committee will be formed consisting of three reputed doctors, preferably a neurologist, psychiatrist and a physician nominated by the High Court in consultation with the state government.
- A committee so formed will examine the condition of the patient and submit its report.
- Simultaneously, a copy of the committee’s report must be submitted to the Court by the person representing the patient.
- The court shall decide the matter expeditiously and in the best interest of the patient. The Court will properly assign the reasons of the decision.
ACKNOWLEDGING THE RIGHT TO DIE WITH DIGNITY- COMMON CAUSE V. UNION OF INDIA
In the year 2005, a registered society called Common Cause filed a Writ Petition under Article 32 before the Hon’ble Supreme Court of India asking to legalize ‘Passive Euthanasia’ and ‘Living Wills’. The question of Passive Euthanasia was raised with the same contention that Article 21 that deals with ‘Right to life’ also includes ‘Right to Die’. Before the filing of PIL, the registered society wrote several letters to the Ministry Of Health and Family Welfare and Ministry of Law and Justice with respect to Passive Euthanasia but did not receive any response from them so they filed the PIL.
- It was argued that the Right to a Dignified Life includes the Right to a Dignified Death. An individual has a right to choose to live or to die.
- It is way better to die rather than to live under intolerable pain and suffering.
- The advanced medical technology has many drugs and medicines available that unnecessarily prolong one’s life causing him and his family a lot of distress and mental agony.
- Euthanasia to terminally ill patients creates an opportunity to donate organs to the people who can be treated by organ transplantation. In this way, Passive Euthanasia does not only protect the Right to die for terminally ill patients but also Right to Life for the patients who need organ transplantation.
- It was argued that Euthanasia is an unnatural termination of one’s life and it is inconsistent with the Right to Life.
- It is the State’s duty to protect the life of an individual and Euthanasia is contrary to such duty.
- Permitting Euthanasia will hamper the process of the invention of new cures and treatment for terminally ill patients.
- Euthanasia will degrade the value and importance of human life.
In the year 2018, the Apex Court in this case has recognized ‘Right to Die with Dignity’ as a Fundamental Right under Article 21. This verdict has also permitted ‘Passive Euthanasia’ for terminally ill patients and allowed removal of life support systems.
SANTHARA- A PRACTICE OF VOLUNTARY DEATH
In Jain religion, there is an ancient religious practice of voluntary death called ‘Santhara’. The word ‘Santhara’ means a way of life which includes a way of dying also. In Jainism, the human body is considered as a residence of the soul which takes rebirth in another human body. Many people go on fasting till death in a ritual named Santhara every year. This religion sermonizes that if a person wants to achieve moksha he must follow the path of abandonment and harmlessness. Moksha means the final emancipation of the soul from the cycle of birth, death, and rebirth. The followers of the Jain religion believe that Moksha can be achieved through Santhara or fasting until death.
On August 10, 2015, the Rajasthan High Court in the case of Nikhil Soni v. Union of India, declared the centuries-old Jain practice of Santhara as illegal. A Public Interest Litigation was filed in May 2006 praying the Jaipur Bench to declare Santhara as illegal. The High Court held that this practice is equivalent to suicide and is punishable under sections 309 and 306 of the IPC.
This decision created many controversies and the Jain followers strongly agitated the verdict of the Court and contended that Santhara is a religious practice protected under Article 25. Rejecting this contention, the Court expressed its opinion that Article 25 protects only those acts that are considered as essential religious practices and held that the practice of Santhara is a penal offence, and the prohibition on such practice would not violate the fundamental right to religious freedom of followers of Jainism. The Court stated that:-
“We do not find that in any of the scriptures, preachings, articles, or the practices followed by the Jain ascetics, the Santhara…has been treated as an essential religious practice, nor is necessarily required for the pursuit of immortality or moksha.”
The Court criminalized Santhara based on two grounds-
Firstly, the guarantee of a right to life under Article 21 does not include the right to die. Therefore, the practice of Santhara is not protected under Article 21.
Secondly, Santhara is not an essential religious practice of Jainism and is therefore not protected by Article 25 which deals with a fundamental right to religion.
RECOMMENDATION OF LAW COMMISSION OF INDIA
The Law Commission of India in the 42nd Report
The Law Commission of India in the 42nd Report recommended abolishing Section 309 of the India Penal Code, 1860. The Indian Penal Code (Amendment) Bill, 1978 was passed by the Rajya Sabha which provided for the abolition of Section 309. But, the Lok Sabha was dissolved before passing the Bill and the Bill lapsed.
The Law Commission of India in the 156th Report
The Law Commission of India in the 196th Report
In the 196th Report of the Law Commission of India which was on ‘Medical Treatment to Terminally Ill Patient’s (Protection of Patients and Medical Practitioners)’, the Law Commission discussed various aspects of Euthanasia and legalized withdrawing of the medical support system of a terminally ill patient. The Law Commission recommended that legislation must be passed to protect the terminally ill patients who take the decision to refuse any medical treatment, hydration, or artificial nutrition so that they are not held guilty under Section 309 IPC. The Commission also recommended that the Doctors who assist such patients to end their lives and works in the best interest of the patients must not be penalized.
The following recommendations were given by the Commission-
- It is to be declared that every ‘competent patient’ suffering from a terminal illness, has a right to choose or refuse medical treatment. The informed decision taken by such a competent patient becomes binding on the doctor. The doctor is bound to be satisfied that the decision taken by the competent patient is an informed decision and such an informed decision must be taken by him independently i.e. without undue influence or pressure from others.
- It was proposed that the doctor shall not withdraw or withhold treatment unless he has obtained an opinion from a body consisting of three expert medical practitioners from a panel prepared by high ranking Authority and the decision to withdraw such treatment must be based on guidelines issued by the Medical Council of India. Also, it was proposed that a Register must be maintained by doctors who propose to withdraw or withhold treatment. The Register must contain the reasons as to the patient is competent or incompetent, why the doctor thinks that the decision of the patient is an informed decision or not, the name, age, sex, and other details of the patient and what is in the patient’s best interest.
- The patient who decides to withdraw or withhold medical treatment must be protected from prosecution for the offence of ‘attempt to commit suicide’ under Sec. 309 of the Indian Penal Code, 1860. In the same way, the doctors must be protected from being prosecuted for ‘abetment of suicide’ under Sections 306 of the Penal Code, 1860, or of culpable homicide not amounting to murder under Sec. 304 IPC when the decision is taken in the best interests of patients and the decision was taken by the patient is well informed. The Commission was of the view that the doctors who comply with the provisions of the Law, must be protected from civil and criminal proceedings.
- It was also recommended that an enabling provision must be provided under which the patients, parents, spouses, relatives, next friend, doctors or hospitals can move to a Divisional Bench of the High Court for obtaining a declaration that the proposed decision of continuing or withdrawing medical treatment be declared as ‘lawful’. The High Court must decide such cases at the earliest and within thirty days. Once a declaration is given by the High Court, it will be binding in subsequent proceedings between the same parties. It is not necessary to move to the High Court in every case. In cases where the decision to withdraw treatment is taken in accordance with the law, it will be deemed to be ‘lawful’.
- The identity of the patient, doctors, hospitals, experts must be kept confidential. So, in the Court proceedings, the persons must be described by the English alphabets. Disclosing of identity is not permissible even after the disposal of the case.
- The Medical Council of India should prepare and publish Guidelines in respect of withdrawing medical treatment. The Council may consult other expert bodies in critical care medicine and publish the guidelines in the Official Gazette or on the website of the Medical Council of India.
The Law Commission in its 241st Report
The Law Commission in its 241st Report which was titled as “Passive Euthanasia-A Relook” discussed elaborately the matter of passive euthanasia in the light of the 196th Law Commission’s Report and the Supreme Court’s decision on Aruna Shanbaug’s case. The 241st report was drafted to clear the ambiguities in the 196th report. The 241st report dealt with passive euthanasia whilst the 196th report was regarding the withdrawal and withholding the medical treatment of terminally ill patients.
Summary of Recommendations in the 241st Report
- Keeping in mind the international lines the Commission recommended legalizing passive euthanasia in India too. The guidelines suggested in the 196th law Commission Report and the Aruna’s case will be considered and there is no legal or constitutional difficulty in the enforcement of such a law in our Nation.
- A patient who is above 16 years and is able to take decision have been allowed to decide the continuation or withdrawal of life support system. The decision taken by such a patient will be followed by the doctors if he is satisfied that it is an informed decision.
- In the case of an incompetent patient who is not able to make an informed decision, the decision will be taken by the relatives or doctor of such a patient whether to continue or stop the further treatment, but it is subject to the clearance by the High Court.
- The High Court on receiving the application under the Bill can call for the opinion of the medical experts and the wishes of the family of such patients. Due regard will be given to the best interests of the patient at the time of making an appropriate decision. While giving an order the court shall act as parens patriae.
- The revised Bill further provided for the safety of doctors and the persons acting under their directions. Doctors are granted immunity from civil and criminal liability provided their actions are within the ambit of the Bill. Also, a similar immunity is provided to a terminally ill patient who is refusing medical treatment.
- Despite the fact that medical treatment has been withheld or withdrawn, it is mandatory for doctors to provide palliative care to competent and incompetent patients.
- The Medical Council of India is required to issue guidelines from time to time with respect to the matter to withdraw or withhold medical assistance to the terminally ill patient.
INTERNATIONAL PERSPECTIVE ON EUTHANASIA
The Hon’ble Court in Aruna Shanbaug’s case discussed the laws on Euthanasia in various countries which are as follows-
The Netherlands in the year 2002 became the first European country that legalized euthanasia and assisted suicide. In Netherland, the process of euthanasia is regulated by the “Termination of Life on Request and Assisted Suicide (Review Procedures) Act”, 2002. Provides that euthanasia and physician-assisted suicide are not penal offences if the attending physician exercises due care as required by law. Euthanasia and physician-assisted suicide is legal in very specific circumstances & cases.
As per the penal code of the Netherlands killing a person on his request is an offence punishable with imprisonment of twelve years or fine and also assisting a person to commit suicide is punishable with imprisonment of three years or fine, but the exception is that law permits a medical review board to vitiate the prosecution against the doctors if he performed Euthanasia on the fulfillment of the following criteria-
- The patient’s diseases and illness should be incurable with no scope of improvement.
- The request by the patient for euthanasia must be free & voluntary and persist over time (the request cannot be obtained under any influence, psychological illness, or drugs).
- The patient must be well aware of his/her condition, prospects and options
- At least one other independent doctor must be consulted to confirm the conditions of the patient.
- The death must be carried out in a medically appropriate way by the doctor or patient, and the doctor must be present.
- The patient must be at least 12 years old (patients between 12 and 16 years of age require the consent of their parents)
The Northern Territory of Australia bypassing The Rights of the Terminally Ill Act, 1996 legalized Euthanasia. In the case of Wake v. Northern Territory of Australia the Supreme Court of Northern Territory of Australia held Euthanasia as legal. But later it was made illegal by legislation named Euthanasia Laws Act, 1997. Recently in 2019 voluntary Euthanasia became legal in the Australian State of Victoria.
In the United States of America, the law maintains the difference between active and passive euthanasia. Active Euthanasia is totally illegal as laid down by the Supreme Court of USA in the cases Washington v. Glucksbergand Vacco v. Quill, whereas physician-assisted dying is legal in the states of Oregon under the Oregon Death with Dignity Act, 1997, and in Washington under Washington Death with Dignity Act, 2008.
In Switzerland Euthanasia is illegal but assisted suicide is legal provided it is not done with any malafide intention. As per Article 115 of the Swiss Penal Code, assisting suicide is a penal offence only if it is done with selfish or malafide motive. It does not require the involvement of a physician nor is that the patient is terminally ill. One loophole in the law relating to Euthanasia in Switzerland is that the recipient of Euthanasia must not necessarily be Citizens which means that citizens of other countries may visit Switzerland and undergo Euthanasia.
In Canada, patients do not have the right to demand euthanasia or assisted suicide. As per section 241(b) of the Criminal Code of Canada, physician-assisted suicide is illegal. In the case of Sue Rodriguez v. British Columbia, a 43 years woman was diagnosed with Amyotrophic Lateral Sclerosis (ALS) so she requested the Supreme Court of Canada to aid her in death. The doctors informed her that her life expectancy was 2 to 14 months and she would lose her ability to breathe and she would not be able to move her body and would be confined to the bed. The Supreme Court rejected her plea of euthanasia and said that in the case of assisted suicide the interest of the state will prevail over an individual’s interest.
In the year 2002 euthanasia was legalized in Belgium. For euthanasia, the patients must suffer from persistent physical or psychological pain arising from an incurable illness. The patients asking for euthanasia must be conscious and must repeat their request for Euthanasia. It must be ensured by the authorities that the poor patients do not ask for mercy killing due to lack of money for medical treatment.
Every euthanasia case has to be filed at the special commission to make sure that regulations are being followed by the doctors.
Life is a valuable asset of a human being who needs to be cherished & protected but sometimes due to pain and suffering individual wishes to end his life. Euthanasia is one such practice where a terminally ill patient decides to end his life, he believes dying is better than living such a dreadful life. The law does not allow an individual to take his life as it is the duty of the state to protect it. Article 21 of the Constitution speaks about the Right to a Dignified Life. This provision ensures that an individual must not only exist but live a quality life. But what if an individual is diagnosed with a terminal illness or an incurable disease where he is no more than a dead body with a little life in it, a body that is merely suffering all the time waiting for death to come. Considering the trouble faced by the terminally ill patients who do not have any scope for improvement, many petitions were filed asking the court to legalize euthanasia. The most prominent case in which euthanasia was discussed is the Aruna Shanbaug case.
The Supreme Court in this case discussed all the prevalent laws on euthanasia implemented in other countries and scanned the situation in the light of human rights and ultimately recognized Passive Euthanasia as legal. The Supreme Court in another case of Common Cause v. Union of India legalized Passive Euthanasia and held that Article 21 includes ‘Right to die with dignity’.
In my opinion, the decision of the Supreme Court is fair enough and is based on equality and justice. The Apex Court has also issued certain guidelines so that the laws legalizing Passive Euthanasia are not misused or do not act as an obstacle in the development and protection of the individuals.
Lastly, I would like to say that a human being is born to live his life with dignity, the day he realizes that he is in a permanent vegetative state and his life is nothing but a burden for him & his family and is becoming terrible day by day, his last wish must be honoured and he must be allowed to die with dignity.
 Dr. Parikh, C.K. (2006). Parikh’s Textbook of Medical Jurisprudence, Forensic Medicine, and Toxicology. 6th
Edition, Page 1.55. New Delhi, CBS Publishers & Distributors.
 Aruna Ramchandra Shanbaug v. Union of India, (2011) 4 SCC 454.
 Merriam Webster, (June 25, 2020, 4:30 pm) https://www.merriam-webster.com/dictionary/euthanasia.
 Airdale N.H.S. Trust v. Bland, 1993 2 W.L.R. 316, 362, House of Lords.
 Aruna Ramchandra Shanbaug v. Union of India, (2011) 4 SCC 454.
 Maneka Gandhi v. Union of India, AIR 1978 SC 597.
 State of Maharashtra v. Maruti Sripati Dubal, (1986) 88 BOMLR 589.
 Chenna Jagadeeswar v. State of Andhra Pradesh, 1988 Cri LJ 549.
 P. Rathinam v. Union of India, (1994) 3 SCC 394.
 Gian Kaur v. State of Punjab, (1996) 2 SCC 648.
 Aruna Ramchandra Shanbaug v. Union of India, (2011) 4 SCC 454.
 Common Cause v. Union of India, (2018) 5 SCC 1.
 Nikhil Soni v. Union of India, 2015 CriLJ 4951.
 Law Commission of India, 42nd Report on Indian Penal Code, (June, 1971).
 Law Commission of India, 156th Report on The Indian Penal Code (Volume I) (August 1997).
 Gian Kaur v. State of Punjab, (1996) 2 SCC 648.
 Law Commission of India, 196th Report on Medical Treatment To Terminally Ill Patients (Protection Of Patients And Medical Practitioners) March 2006 (Volume I) (March 2006).
 Law Commission of India, 241st Report on Passive Euthanasia — A Relook, (August 2012).
 Wake v. Northern Territory of Australia, (1996) 109 NTR 1.
 Washington v. Glucksberg, 521 US 702 (1997).
 Vacco v. Quill, 521 US 793 (1997).
 Sue Rodriguez v. British Columbia (Attorney General), (1993) 3 SCR 519.